Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Coats v. Reliance Standard Life Insurance Policy

United States District Court, N.D. Oklahoma

April 27, 2017

JENNIFER COATS, Plaintiff,
v.
RELIANCE STANDARD LIFE INSURANCE POLICY, Defendant.

          OPINION AND ORDER

         Before the Court is Plaintiff's Motion for Partial Summary Judgment (Doc. 17).

         I. Factual Background

         On April 2, 2012, Plaintiff Jennifer Coats became employed as a staff nurse with Cottage Health Care (“Cottage”). Plaintiff became a participant in Cottage's employee welfare benefit plan (the “Plan”), which is governed by the Employee Retirement Income Security Act of 1974 (“ERISA”). The Plan includes long-term disability (“LTD”) benefits funded by Defendant Reliance Standard Life Insurance Company (“Reliance”) through Group Policy No. LSC 97, 200. The Plan provides that Reliance “shall serve as the claims review fiduciary with respect to the insurance policy and the Plan”; shall “determine eligibility for benefits”; and shall make “complete, final and binding decisions on all parties.” (AR 18.)

         On October 19, 2013, Plaintiff suffered an on-the-job back injury and has not returned to work since that time. Plaintiff submitted a claim for LTD benefits with Reliance on March 24, 2015. By letter dated June 11, 2015, Reliance approved the claim and granted Plaintiff $2, 194.96 in monthly LTD benefits.

         Believing the award was insufficient, Plaintiff filed an administrative appeal of the adverse benefit determination on December 3, 2015. On January 25, 2016, outside the 45-day deadline in the relevant ERISA regulation, Reliance sent a letter to Plaintiff stating:

We are required to make a decision within 45 days of the date of your appeal but are allowed an additional 45 days if circumstances do not permit us to make a decision within the initial 45 day time frame. Please allow this letter to serve as notice of our intention to take beyond 45 days to make a final decision on your appeal. As we are still in the process of completing our review, we will be contacting you in the near future with an update or to inform you if additional information will be required.

(AR 187.)

         On April 5, 2016, having heard nothing from Reliance regarding her LTD claim, [1] Plaintiff filed the instant case in Tulsa County, alleging underpayment of ERISA benefits and breach of fiduciary duty. Plaintiff alleges that Reliance failed to adjudicate her appeal in accordance with the Plan or applicable law, that the appeal was deemed denied and exhausted, and that her civil action was permissible to recover underpaid amounts. Reliance received process in this case sometime between April 8 and April 11, 2016. On April 20, 2016, Reliance denied the appeal. On April 27, 2016, Reliance removed the case to this Court, and the Court set a briefing schedule governing the preliminary issue of the proper standard of review.

         Currently before the Court is Plaintiff's motion for partial summary judgment on the question of the proper standard of review. Based on undisputed facts in the administrative record, Plaintiff contends that Reliance resolved Plaintiff's appeal outside of ERISA's mandated deadlines. According to Plaintiff, this violation negates the “arbitrary and capricious” standard normally applied and results in a de novo standard of review. Reliance does not dispute that its decision was untimely but argues: (1) untimeliness is not a procedural irregularity that alters the standard of review; and, alternatively, (2) a “substantial compliance” exception applies because Plaintiff “was not prejudiced by the timing of the appeal decision.” (Resp. to Mot. for Partial Summ. J. 8.)

         II. Summary Judgment Standard

         Summary judgment is proper only if “there is no genuine issue as to any material fact, and the moving party is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(c). The moving party bears the burden of showing that no genuine issue of material fact exists. See Zamora v. Elite Logistics, Inc., 449 F.3d 1106, 1112 (10th Cir. 2006). The Court resolves all factual disputes and draws all reasonable inferences in favor of the non-moving party. Id. However, the party seeking to overcome a motion for summary judgment may not “rest on mere allegations” in its complaint but must “set forth specific facts showing that there is a genuine issue for trial.” Fed.R.Civ.P. 56(e). The party seeking to overcome a motion for summary judgment must also make a showing sufficient to establish the existence of those elements essential to that party's case. See Celotex Corp. v. Catrett, 477 U.S. 317, 323-33 (1986).

         III. Analysis

         A. Does Untimeliness of Reliance's Decision Alter the Standard of Review?

         Because Reliance does not dispute that its decision was untimely, the first question presented is purely legal - whether the untimeliness of its decision alters the arbitrary and capricious standard of review. If a benefit plan gives the administrator discretionary authority to determine eligibility for benefits or to construe the terms of the plan, such as the Plan at issue here, a court ordinarily employs a deferential “arbitrary and capricious” standard of review. LaAsmar v. Phelps DodgeCorp. Life, Accidental Death & Dismemberment & Dependent Life Ins. Plan, 605 F.3d 789, 796 (10th Cir. 2010) (citing Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101, ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.